With the first GloBE Information Return (GIR) filings due by 30 June 2026 for many multinational enterprise (MNE) groups, attention is increasingly shifting from policy to implementation. While the GIR may appear straightforward in its published form, the underlying technical requirements introduce a level of complexity that is often underestimated.
From PDF to XML: The Hidden Complexity
The OECD has published the GIR in two forms:
- A human-readable PDF, and
- A machine-readable schema (XSD)
While the PDF provides a conceptual view of the required data, the actual filing is made in XML format, built strictly according to the XSD schema.
In simple terms:
- The XSD schema defines the structure and rules
- The XML file contains the actual reported data
The key point is that the XML submission must fully comply with the XSD schema, which is significantly more detailed and rigid than the PDF representation suggests.
The Role of XSD Schemas
The XSD schema acts as a technical blueprint for the GIR. It specifies:
- Which data elements must be included
- The format and data type of each field
- The order in which elements must appear
- Whether elements can repeat or are conditional
This ensures that GIR filings can be processed consistently by tax authority systems.
However, in practice, the OECD schema is often only the starting point.
Jurisdictional Variations
Many jurisdictions:
- Adopt the OECD schema as a base, and
- Introduce local extensions or additional fields to meet domestic requirements
Some jurisdictions go further and develop their own schemas. The Netherlands is one example where a distinct local schema has been introduced.
As a result, MNEs are not dealing with a single global standard, but a growing set of jurisdiction-specific implementations.
Validation Rules: Beyond Structural Compliance
Compliance with the XSD schema is only one part of the process.
GIR filings are also subject to validation rules, which assess whether the data is logically consistent and complete.
These operate at two levels:
1. Structural validation (XSD-based)
Ensures the file is technically correct:
- Required fields are present
- Data types are respected
- Structure and sequencing are valid
2. Business validation rules
Ensures the data itself is coherent:
- Totals reconcile across sections
- Relationships between data points are consistent
- Values fall within expected ranges
- Conditional fields are correctly populated
An XML file may pass structural validation but still fail business validation, leading to rejection or follow-up queries.
Practical Challenges for MNEs
In practice, the combination of:
- Evolving jurisdictional schemas
- Differing validation rules
- Tight filing timelines
creates a challenging environment for MNEs.
A common issue is the iterative nature of validation:
Due to the interconnected nature of schema constraints and validation rules,
- Fixing one issue may surface additional dependencies
- Multiple rounds of correction may be required
- These issues often surface late in the process
As the filing deadline approaches, this can lead to bottlenecks, particularly if many groups are attempting to validate and submit simultaneously.
In addition, taxpayers typically do not have visibility into whether GIRs are successfully exchanged between jurisdictions, adding another layer of uncertainty to the process.
These challenges are often underestimated until organisations begin working directly with XML filings and validation processes.
Ongoing Developments
Adding to the complexity, GIR schemas and validation rules remain in flux across many jurisdictions. In some cases:
- Technical specifications have not yet been finalised
- Updates continue to be released
- Validation requirements evolve over time
While core OECD structures are stable, jurisdiction-specific implementations and validation rules continue to evolve.
Orbitax’s approach
At Orbitax, we continuously review and analyze local GIR schemas and validation rules, comparing them against the OECD baseline. Based on this, we develop and maintain jurisdiction-specific schemas and validations within the Orbitax International Tax Platform.
At time of publication of this article, local GIR schemas are available for a growing number of jurisdictions, including the UK, Netherlands, Germany, Australia, Italy, Canada, Ireland, Belgium, Liechtenstein, Hungary, Finland, France, Sweden, Luxembourg, and Austria, with additional jurisdictions being added as technical specifications are finalised by the authorities.
Conclusion
The GloBE Information Return is not simply a reporting exercise, it is a structured data submission process. While the policy framework is well understood, the technical implementation introduces a layer of complexity that is only fully apparent during preparation and filing.
As the June 2026 deadline approaches, early preparation and validation testing will be critical.
Disclaimer: This article is intended for general informational purposes only and does not constitute tax or legal advice. Requirements may vary by jurisdiction.